As a pass-through entity of federal awards, Kentucky Emergency Management (KYEM) must monitor subrecipients to ensure compliance associated laws, regulations, policies, and procedures. Subrecipient monitoring is conducted for all KYEM grant programs, within all stages of the award, including closeout.
Grant Management Site Visits
Grant management site visits are an integral part of the subrecipient monitoring process. Site visits are conducted on an annual basis. The site visit may be conducted by a KYEM program manager, KYEM Area Manager, or the KYEM Subrecipient Monitor. During the site visit, the KYEM representative will review documentation, visit project locations, and meet with local program representatives.
With the release of the new federal government Uniform Guidance, 2 CFR 200 in December 2014, assessing risk on subrecipients is now a requirement of pass-through agencies. The purpose of the assessment is to determine if subrecipients of federal awards are capable of managing the funds in accordance with the award stipulations.
Per 2 CFR 200.331 (b) -
The pass-through entity (KYEM) must evaluate the risk of non-compliance for each subrecipient to determine the appropriate level of subrecipient monitoring.
Multiple avenues are used to determine the risk associated with KYEM subrecipients:
1. Review of annual audits to include the A-133 Single Audit
2. Grant Management Site Visits
3. Submission of the annual Risk Assessment
4. Submission of the annual Financial Assessment
5. On-going review of submitted documentation for reimbursement of federal funds.
In the United States, the Single Audit, also known as the OMB A-133 audit, is a rigorous, organization-wide audit or examination of an entity that expends $750,000 or more of Federal assistance (commonly known as Federal funds, Federal grants, or Federal awards) received for its operations. (www.wikipedia.org)
Per 2 CFR 200.512(a): Single audits must be completed within 9 months of the closure of the subrecipient’s fiscal year. (Ex: June 30 fiscal year closure, single audit completion date of no later than the following March 30)
Guidelines, Forms, and Links